SEC Comment Letter for GoRemote Internet Communications, Inc. (CIK 0001059155) — Oct 18, 2004
GoRemote Internet Communications, Inc. (CIK 0001059155)
Date: Oct. 18, 2004 · CIK: 0001059155 · Accession: 0000000000-04-033393
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<DOCUMENT> <TYPE>LETTER <SEQUENCE>1 <FILENAME>goremote2letter.txt <DESCRIPTION>ITEM 4 8-K COMMENT LETTER 10/18/04 (GILMORE) <TEXT> October 18, 2004 Mail Stop: 4-6 Daniel W. Fairfax Chief Financial Officer GoRemote Internet Communications, Inc. 1421 McCarthy Blvd. Milpitas, CA 95035 Re: Item 4 Form 8-K filed October 11, 2004 Dear Mr. Fairfax: We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments. Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. 1. Amend the report to include disclosure to state whether during the registrant`s two most recent fiscal years and any subsequent interim period through the date of resignation, whether there were any disagreements with the former accountant on any matter of accounting principles or practices, financial statement disclosure, or auditing scope or procedure, which disagreement(s), if not resolved to the satisfaction of the former accountant, would have caused it to make reference to the subject matter of the disagreement(s) in connection with its reports. In the event of disagreement(s) and/or reportable event(s), provide the specific disclosures required by Item 304(a)(1)(iv) and (v) of Regulation S-K. 2. Please file a letter from your former accountant, indicating whether or not they agree with your disclosures in the Form 8-K. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that * the company is responsible for the adequacy and accuracy of the disclosure in the filings; * staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and * the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing. Please respond to these comments within 5 business days or tell us when you will provide us with a response. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please file your cover letter on EDGAR. Please understand that we may have additional comments after reviewing your amendment and responses to our comments. You may contact the undersigned at 202-824-5355 if you have questions regarding these comments. Sincerely, Patrick Gilmore, CPA Staff Accountant Daniel W. Fairfax GoRemote Internet Communications, Inc. Page 2 of 2 </TEXT> </DOCUMENT>